Company

Ethics & Conduct

Conducting our business ethically is one of Universal Avionics Systems Corporation’s (the “Company”) core values. Our policy is to follow best practice compliance standards applicable to the broad range of our global activities. Because of the significance we place on the transparency of our ethical business conduct, the following codes, policies and procedures are all publicly available as provided below.

Code of Business Conduct and Ethics

Conducting our business ethically and consistent with best practices and legal requirements is essential to our success. Attached is our Code of Business Conduct and Ethics, as approved by the Company's Board of Directors.

As part of our business ethics compliance policy, we encourage reporting of suspected violations of our policies, improper conduct and legal non-compliance. We are committed to taking such reports seriously, investigating them in a prompt and discrete manner, and we do not tolerate retaliation against employees who report in good faith. Attached is our Whistleblower and Investigations Procedure, which describes the methods for reporting and the process we follow to investigate such reports.

The international nature of our business and our work with governmental customers and end users around the world, as well as our being a publicly traded company, requires us to follow leading anti-bribery and corruption compliance standards. We have zero tolerance for corruption, and our employees, officers and directors are committed to conducting our business according to applicable anti-bribery and corruption compliance practices. Attached is our Anti-Bribery and Corruption Compliance Policy.

An important part of our anti-bribery and corruption compliance policy is the due diligence we conduct with respect to third parties with whom we do business. Attached is our Procedure on Anti-Bribery and Corruption Due Diligence (without Annexes).

Another important aspect of our anti-bribery and corruption compliance policy, as well as our policy for avoiding potential conflicts of interest, is the way in which we provide and receive business entertainment, hospitality and gifts. Attached is our BusinessEntertainment and Gifts Policy (without Annexes).

We support government and industry initiatives to increase supply chain transparency to facilitate the ability of companies to source "conflict-free minerals." We are also committed to sourcing materials from companies that share our values with respect to conflict minerals, as reflected in our attached Conflict Minerals Compliance Policy.